People vs. Galit
[GR 51770, 20 March 1985]
In August 23, 1977, Mrs. Natividad Fernando was found dead in her bedroom as a result of 7 wounds inflicted in her body. More than 2 weeks thereafter, the police authorities of Montalban picked up defendant-appellant, Francisco Galit on suspicion of the murder on the occasion of a robbery. When the case was referred to the NBI, NBI Agent Flores conducted a preliminary interview of the suspect who allegedly gave evasive answers to his questions. The following day, Francisco Galit allegedly voluntarily executed a “Salaysay” admitting his participation in the commission of the crime and implicating two other persons as his companions. In reality, Galit had been obtained and interrogated almost continuously for 5 days, but to no avail as he consistently maintained his innocence. The investigating officers began to maul him and to torture him physically. Galit admitted what the investigating officers wanted him to admit to the crime and he signed the confession they prepared. Galit was charged with the Crime of Robbery with Homicide, was found guilty with the sentence of death penalty. Hence, the automatic review.
Whether or not a monosyllabic answer to a long question suffices as a voluntary admission that may be used against the accused?
Herein, the only evidence against Galit is his alleged confession. A long question followed by a monosyllabic answer does not satisfy the requirements of the law that the accused be informed of his rights under the Constitution and our laws. Instead there should be several short and clear questions and every right explained in simple words in a dialect or language known to the person under investigation. Galit is from Samar and there is no showing that he understands Tagalog. Moreover, at the time of his arrest, Galit was not permitted to communicate with his lawyer, a relative, or a friend. In fact, his sisters and other relatives did not know that...
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